Respondents' Original Answer - Page 1 of 6
Respondents' Original Answer - Page 1 of 6
141-214752-05
Respondents in the above-entitled and numbered cause, and file this Original Answer, and show
the Court:
I.
GENERAL DENIAL
Respondents deny each and every allegation of Applicant’s Application to Foreclose, and
demand strict proof by a preponderance of the credible evidence thereof as required by the Texas
II.
VERIFIED DENIALS
A. Conditions precedent to the filing of suit have not been satisfied as alleged.
AFFIRMATIVE DEFENSES
IV.
ATTORNEY’S FEES
Respondents have retained the services of Larry E. Meadows, of Meadows & Associates,
L.L.P., to protect Defendants’ rights in this matter. Respondents have agreed to pay the
reasonable and necessary fees charged by said attorney. Respondents request that all fees
incurred as a result of this representation be paid by Plaintiffs and attached as costs or that
judgment be rendered against Plaintiffs and in favor of Respondents for attorney’s fees, if and
PRAYER
Respondents pray the Court, and after notice and hearing or trial, enters judgment in
favor of Respondents, awards Respondents the costs of court, attorney's fees, and such other and
Respectfully submitted,
_____________________________________________________________________________
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Respondents’ Original Answer - Page 2 of 6
MEADOWS & ASSOCIATES, L.L.P.
By:
Larry E. Meadows
Texas Bar No. 24010835
Kelly C. Gent
Texas Bar No. 24038916
P.O. Box 77045
Fort Worth, Texas 76177
Tel. (817) 745-1550
Fax. (817) 745-1551
Attorneys for Respondents
Abid H. Sheikh and Shakeem A. Sheikh
_____________________________________________________________________________
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Respondents’ Original Answer - Page 3 of 6
NO. 141-214752-05
VERIFICATION
BEFORE ME, the undersigned authority, personally appeared Abid H. Sheikh, who
"My name is Abid H. Sheikh. I am at least 18 years of age and of sound mind. I am
personally acquainted with the facts alleged in Respondents' Verified Denials. I hereby swear
that the statements in support of Respondents' Verified Denials are true and correct."
Abid H. Sheikh
_____________________________________________________________________________
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Respondents’ Original Answer - Page 4 of 6
NO. 141-214752-05
VERIFICATION
BEFORE ME, the undersigned authority, personally appeared Shakeem A. Sheikh, who
"My name is Shakeem A. Sheikh. I am at least 18 years of age and of sound mind. I am
personally acquainted with the facts alleged in Respondents' Verified Denials. I hereby swear
that the statements in support of Respondents ' Plea in Verified Denials are true and correct."
Shakeem A. Sheikh
Bridget A. Braithwaite
Barrett, Burke, Willson, Castle, Daffin and Frappier, LLP
15000 Surveyor Blvd.
Suite 100
Addison, Texas 75001
972.341.0673 (Fax)
Larry E. Meadows
_____________________________________________________________________________
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Respondents’ Original Answer - Page 6 of 6